Privacy Policy


  • In this statement, the following terms shall have their respective meanings:


"data subject", in relation to personal data, means the individual who is the subject of the data;


"Group" means  the Company and its subsidiaries, holding companies, subsidiaries of those holding companies and other associated or related entities; 


"Hong Kong" means the Hong Kong Special Administrative Region of the People's Republic of China;


"non-personal data" means any data not falling within the meaning of "personal data";


"PDPO" means the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong);


"personal data" means any data:


  • relating directly or indirectly to a living individual;


  • from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and


  • in a form in which access to or processing of the data is practicable;


  • Unless stated otherwise, capitalized terms used in this statement shall have the same meaning given to them in the Terms and Conditions.


  • The Company is committed to providing you with high-quality e-commerce platform solutions and related support services. Based on your service needs, we will collect and use different types of your personal data and non-personal data. We treat the use and confidentiality of your personal data and non-personal data seriously.


  • The security and privacy of your personal data and non-personal data is a matter of utmost importance for the Company. We are committed to protecting the privacy, confidentiality, and security of your personal data and non-personal data; in the case of personal data by complying with the requirements of the PDPO through the implementation of the policies set out in this statement.


  • Where our operations are also subject to privacy legislation other than that of Hong Kong, we will seek to comply with all such applicable law to the extent that it is possible for us to do so. Where there is a conflict between different systems of laws, we will, in most cases, comply with the system of law that imposes a stricter standard on us.


  • The Company reserves the right from time to time to revise this statement. Where any changes to this statement are material, The Company will notify you using the contact details which you have provided the Company and by updating and issuing the new version on the Site. You are advised to check the statement periodically and pay attention to its revision. After the publication of the new version of this statement, your continued use of the Site or your continued relationship with the Company shall be deemed to be acceptance of and consent to this updated statement, as amended from time to time.


Collection and Use of Data


  • The Company may collect personal data provided voluntarily by users of the Site and/or the Services either directly or through a third-party platform, when you apply, subscribe and register for our products and Services, click on advertisements we place on relevant third-party platforms, participate in our operation activities or contact us for any requests or consultations.


  • Users (including corporate users) and/or their representatives may be required to provide us with, including but not limited to the following data:


  • name, job title, company name (where applicable), email address, telephone number, username and password (where applicable), user profile photo (where applicable), address and other contact information, and location data such as country and region;


  • records and history relating to your use of the Services;


  • invoicing information, bank account information (e.g. account number, bank name and SWIFT/ABA code where applicable), credit card or other payment method information processed via our payment service providers (where applicable), and payment proof information (e.g. bank transfer receipt);


  • government identification and/or proof of address only where required for contracting, account security, fraud prevention or compliance, and, where provided, electronic signature (where applicable);


  • certificate of incorporation and/or business registration information, registered/operating address, authorized representatives/signatories and relevant corporate contact persons, names of affiliated entities (where relevant to service delivery), and constitutional documents only where necessary for contracting or onboarding; and


  • IP address, cookies, browser type and version, time zone settings, browser plug-in types, operating systems or platform, device type/model, and general network data.


  • The Company may also obtain your personal data from publicly available sources of information, recording telephone conversations and/or communications by using electronic media, or from third party risk intelligence applications that you have made public via your privacy settings with that third party.


  • The Company may also collect the following technical data automatically when you visit the Site and/or use the Services: 


  • IP address, cookies;


  • login information;


  • operating system;


  • access channel (e.g. web browser/ mobile browser) and, where applicable, our mobile application;


  • device type, model and related operation system;


  • browser type and version, and plug-in information (where available);


  • time and date of consent and the relevant Site/page;


  • language, geographical location and time zone settings; 


  • information about your visit to the Site and/or any e-commerce storefront or platform we operate (where applicable), including pages viewed, searches, filters, items added to cart or purchased, the hyperlinks you have clicked, site usage including page viewed and page response times, download errors, length of visits to certain pages, page interaction information and methods used to browse the Site.


  • Your personal data and non-personal data will be recorded when you visit the Site or use the Services, which will then be used for the purposes of data analysis, including analyzing the number of visitors to the Site. This may include saving cookies to your computer or mobile device. Cookies are data files stored on your browsers. This Site automatically installs and uses cookies on your browsers when you access it, which are used to store your preferences, enhance the function of the Site, and facilitate your browsing. The cookies used in connection with the Site do not contain personal data. You may refuse to accept cookies on your browsers by modifying the settings in your browsers or internet security software. However, if you do so you may not be able to utilize or activate certain functions available on the Site. 


  • We will only use the personal data we collect for the purposes set out in this statement. We will obtain your consent before using your personal data for other purposes, unless otherwise permitted by applicable law. If you do not supply the personal data requested, we may not be able to provide or continue to provide the Services to you. Your personal data (whether individually, or aggregated with the personal data of other people) may be used for the following purposes: 


  • Administering your accounts and providing you with our products or Services;


  • Conducting data matching procedures (as defined in s.2 of the PDPO) for fraud prevention, account security and eligibility assessments;


  • Facilitating electronic signature and authentication for contracting and service delivery (where applicable);


  • Dealing with and processing service applications, subscriptions and registration submitted by you for our products and Services;


  • Conducting verification and security checks, fraud detection, and service-related risk management;


  • Designing new and/or enhancing existing services, products, activities, and/or other events relating to our products or Services;


  • Responding to and processing your enquiries and taking further actions or following up as required;


  • Promoting and marketing certain existing and future services and products to you (please refer to the section entitled "Use of Data in Promotion and Direct Marketing" below for further details);


  • Providing you with the online services available at the Site and/or through other telecommunication channels;


  • Determining fees and charges payable to us (if applicable);


  • Collecting overdue payments and enforcing payment obligations (if applicable);


  • Complying with any applicable laws, rules, regulations, court orders or the requests or requirements of any regulatory body and carrying out obligations arising from any agreements entered between you and us;


  • Enabling any of our actual or proposed transferees / assignees to assess any proposed merger, re-organization or other similar process;


  • Any purposes allowed by applicable laws;


  • Defending our rights or participating in any legal or administrative proceedings;


  • Conducting marketing research, surveys, analysis and other similar activities from time to time;


  • Generating unique internal identification numbers for organizational and reporting purposes and other forms of statistical analysis;


  • Generating anonymized statistics, information and reports for the design, improvement, marketing or provision of our Services; 


  • Compiling general statistics in relation to the number of users to the Site and the usage of the Site or the Services; 


  • Using your personal data for AI-enabled analytics to improve our Services, enhance platform performance and provide personalized recommendations (where applicable); 


  • Using the information that the Site collects about you to improve your experience while using the Services; and


  • Any functions related to the foregoing.


  • The Company may be required to retain, process and/or disclose your personal data to agents, contractors or other third-party service providers, to which the Company does not assume any liability for any loss or damage that you may sustain, in order to:


  • comply with a court order, subpoena or other legal process (whether in Hong Kong or elsewhere); 


  • comply with applicable laws and regulations;


  • comply with a request by a government authority, law enforcement agency or similar body (whether situated in Hong Kong or elsewhere);


  • provide to third-party service providers who support our operations for the purposes set out in this statement;


  • provide to any third party to whom the Company's businesses or any part of the Company's businesses will be sold, assigned or transferred to, if applicable; or


  • as the Company may need to retain, process and/or disclose your personal data in order to enforce any agreement with you, protect the Company's rights, property or safety, or the rights, property or safety of the Company's employees.


De-identified or Aggregate Information


  • We may use the information we have about you to create de-identified or aggregate information, such as de-identified demographic or location information, information about devices used to access our Services, or other relevant analyses. Such data cannot be associated with a specific individual. We may perform our analytics on such data or share it with any third-parties.


Third Party Websites


  • The Site may from time to time contain linkages to other websites. These other websites are independent from the Site. The Company has no control or management over the contents of such other websites or their privacy policies or compliance with the law. You should be fully aware that the provisions of such linkages do not constitute an endorsement, approval, or any form of association by or with the Company and the Company has no control over the personal data submitted by you, if any, to other websites.


Our Policy Towards Children


  • Our Services are not intended for children, so we restrict anyone below the age of 18 years or below the age of legal majority in the relevant jurisdiction from using our Services. We do not knowingly or intentionally collect and process any data related to children.


  • We may not be able to determine a user’s age in all circumstances. If we become aware that a child has provided us with personal data, we will take steps to delete such information as soon as possible.


Disclosure of Personal Data


  • Personal data held by the Company will be kept confidential, but may be disclosed to the following persons for one or more of the purposes set out in paragraph 12 above:


  • Any of our officers, employees, agents, affiliates, contractors and third-party service providers who support our business operations on a need-to-know basis and subject to appropriate contractual and security safeguards;


  • Any member of the Group;


  • Any actual or proposed assignee or transferee of the Company, or participant or sub-participant or transferee of the Company in respect of our rights against you;


  • Professional advisers (including legal, accounting and financial advisers) engaged by the Company; and


  • Any local or foreign regulatory agency, body, government, tax authority, law enforcement agency, administrative or statutory agency in Hong Kong or other places for compliance with applicable laws, regulations, rules or guidelines.


  • The Company will adopt contractual and/or other means to ensure the agents, contractors or other third-party data processors who process personal data on behalf of the Company will take all reasonable steps to (i) protect the personal data they hold against unauthorized or accidental access, processing, erasure, loss or use; and (ii) ensure that personal data will not be kept longer than necessary.


  • The Company may transfer your personal data to a place outside Hong Kong in accordance with this statement. Your personal data may not be afforded the same or similar level of protection as it is under the PDPO.


  • As the Company continues to develop its business, it may reorganize its business structure, undergo a change of control or business combination. In these circumstances it may be the case that your personal data is transferred to a third party who will continue to operate the Company's business or a similar service under either this statement or a different privacy policy and personal information collection statement which will be notified to you. Such a third party may be located, and use of your personal data may be made in connection with such acquisition or reorganization outside your country or region of location.


Use of Data in Promotion or Direct Marketing


  • The Company may use your personal data to send you information about products, services and other marketing materials such as news, promotions, events and marketing offers that we think you might be interested in.


  • You can choose to receive direct marketing materials by email, direct mail and/or other means. If you do not wish to receive such direct marketing materials, you may elect to opt-out at any time by contacting our Customer Service Department. The Company intends to use your personal data for direct marketing purposes, for which we have to obtain your consent (which includes an indication of no objection). In this regard, please note that:


  • Your name, contact details and (where applicable) account information, as well as information about your use of the Site and/or services (such as service preferences and interaction data), may be used for direct marketing;


  • The following categories of services, products and subjects may be marketed to you: (i) e-commerce platform solutions and related support services; (ii) online marketing, promotional and SEO services; (iii) analytics and performance optimization tools and services (including AI-enabled features where applicable); and (iv) events, seminars, newsletters and materials related to the foregoing; and


  • The above services, products and subjects may be marketed by the Company and/or (where applicable) any member of the Group, and our business partners that provide services related to e-commerce, marketing, analytics or technology (the names of such partners will be provided to you where required);


  • In addition to promoting the above services, products and subjects, the Company may provide the personal data mentioned in paragraph 23(A) to any of the persons as mentioned in paragraph 23(C) above for the purpose of promoting their services, products and subjects. In order for us to do so, we need to obtain your consent (which includes an indication of no objection) for this purpose;


  • If you do not wish the Company to use or provide your personal data to other persons for the direct marketing purposes set out in paragraph 23(D), please notify our Customer Service Department; and


  • We may receive money or other property in return for providing your personal data to the other persons in paragraph 23(D) and, when requesting your consent or no objection we will inform you if we receive any money or other property in return for providing the personal data to the other persons.


Providing Another Person's Personal Data


  • Where you provide to us personal data about another person, you must obtain their consent and give to that person a copy of this statement and, in particular, tell him/her that you have provided us with their personal data and how we may use his/her personal data.

        

Personal Data Protection Measures


  • All personal data provided to the Company will be securely stored with restricted access by authorized personnel only. We utilize encryption/security software for data transmission so as to protect your data via encrypting it in a secure format to ensure its privacy and security from unauthorized access or disclosure, accidental loss, alteration or destruction.


  • The Company implements protective measures to safeguard and secure personal data to ensure it is protected against unauthorized or accidental access, processing, erasure, loss or use; and prevents any personal data from being kept longer than is necessary for processing of the data. These measures include the following：


  • Access or use of such data is limited to authorized staff or agents on a “need to know” basis and such data is accessed utilizing secured methods (e.g. personal data is encrypted when necessary);


  • We do not distribute your personal data to other persons except to the classes of transferees set out in this statement and for the purposes set out in this statement;


  • The use and transfer of your personal data between members of the Group is subject to strict internal security standards, confidentiality policies, privacy laws and other applicable laws;


  • We ensure that our employees fully comply with such standards, policies and laws; and


  • We provide training to our staff on the proper handling of your personal data.


  • As we further develop new products and services, we will continue to make every effort to ensure that your personal data is properly used and protected.


  • Nevertheless, the transmission of information via the internet is not completely secure. Although the Company will do its best to protect your personal data, the Company cannot guarantee the security of data transmitted to the Site. Once your personal data is received, the Company will use strict procedures and security features to try to prevent unauthorized access.


Data Access and Correction Requests


  • According to and in accordance with the terms of the PDPO, you have the right to:


  • obtain information regarding the processing of your personal data and access to the personal data which we hold about you;


  • request that we rectify your personal data if it is inaccurate or incomplete; and


  • lodge a complaint with the Privacy Commissioner for Personal Data if you think that any of your data privacy rights have been infringed by us.


  • We will take all practical steps to erase personal data that is no longer required for the purpose for which the data is used, unless erasure is prohibited by applicable  law or is not in the public interest. You may ask that we erase some or all of your personal data, but please note that it may not be legally or operationally possible for us to do so.


  • If there is a change to any of the personal data that you have provided to us, please contact our Customer Service Department.


Please indicate your name, your contact details, and any relevant reference information for us to follow up with your request. You may be asked to provide additional information to authenticate your identity in order for us to follow up with your request.


  • In accordance with the terms of the PDPO, the Company reserves the right to charge a reasonable fee for processing any data request.


  • The Company will take reasonable steps to ensure the accuracy of your personal data held by the Company. If the Company becomes aware that the personal data is inaccurate, the Company will not use such data and will notify any third party to which such personal data has been transferred regarding the same.


  • Nothing in this statement shall limit your rights under the PDPO.


Retention Period of Personal Data


  • We will not keep personal data longer than is necessary for the fulfillment of the purpose for which it was collected unless a longer retention period is required or permitted by applicable laws, rules and regulations. The retention period of personal data collected depends on different factors, including:


  • Usage: we may have to continue to retain the personal data for the purpose(s) for which it was collected for; and


  • Legal obligations: there may be minimum retention periods for that personal data, as stipulated in applicable laws and regulations.


Termination or cancellation


  • Should your relationship with the Company be cancelled or terminated at any time, the Company shall cease processing your personal data as soon as reasonably practicable following such cancellation or termination, provided that the Company may keep copies of the data as is reasonably required for reasonable purposes, such reasonable purposes shall include keeping of records, use in relation to any actual or potential dispute, complying with applicable laws and regulations, and protecting the Company's rights, property or safety, or the rights, property or safety of the Company's employees and agents.


This statement is made in the English language. This statement may be translated to other languages for convenience only, and in the event of any inconsistency, the English language version will prevail.